Aaron J. Schlaphoff

Sep 19, 2024 | lexology.com | H. Christopher Boehning |Jessica Carey |John Carlin |Andrew J. Ehrlich |Roberto González |Brad S. Karp | +7 more

On August 28, 2024, the Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a rule (the “Final Rule”) imposing new anti-money laundering/countering the financing of terrorism (“AML/CFT”) standards on certain investment advisers (“Covered Investment Advisers”).[1] The Final Rule finalizes a draft that FinCEN proposed in its February 2024 Notice of Proposed Rulemaking (“NPRM”), with certain changes as discussed below.[2] Although the Final Rule does not take...

Feb 21, 2024 | lexology.com | H. Christopher Boehning |Jessica Carey |John Carlin |David C. Fein |Michael E. Gertzman |Roberto González | +4 more

On February 13, 2024, the Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) published a proposed rule aimed at “keep[ing] criminals and foreign adversaries from exploiting the U.S. financial system and assets through investment advisers” (the “Proposed Rule”).[1] The Proposed Rule would require SEC-registered investment advisers (“RIAs”) and exempt reporting advisers (“ERAs”) (together, “Covered Investment Advisers”) to establish anti-money laundering/countering the...

Nov 27, 2023 | lexology.com | Jarryd E. Anderson |Jessica Carey |Roberto González |Matthew Jordan |Aaron J. Schlaphoff

On January 1, 2024, the Beneficial Ownership Reporting Rule (as defined below) under the Corporate Transparency Act (the “CTA”)[1] goes into effect. The Beneficial Ownership Reporting Rule will require certain non-exempt entities to disclose previously unrequired information or face potential civil and criminal penalties. We discuss several key requirements and legal considerations below.